PTAB

IPR2026-00154

Target Corp v. Headwater Research LLC

Log In
Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Message Link Server With Plural Message Delivery Triggers
  • Brief Description: The ’192 patent describes a message link server that manages communication with multiple wireless end-user devices. The server uses a buffer system to store messages received from network elements and delivers the buffered content over a secure link only when one of several predefined message delivery triggers occurs.

3. Grounds for Unpatentability

Ground 1: Obviousness over TS-23.140 - Claims 1, 5-7, 9, 11-13, and 15 are obvious over TS-23.140

  • Prior Art Relied Upon: TS-23.140 (a 3rd Generation Partnership Project (3GPP) technical specification for Multimedia Messaging Service (MMS)).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the 3GPP MMS standard, as detailed in TS-23.140, inherently disclosed all limitations of the challenged claims. The "MMS Relay/Server" in TS-23.140 was alleged to be the claimed "message link server." Petitioner contended this server uses a "transport services stack" (MM1 Transfer Protocol with TCP/IP and Transport Layer Security (TLS)) to maintain a "secure message link" with "User Agents" (device link agents) on mobile devices. The specification’s description of storing messages in a "Persistent Network-Based Storage" or "MMBox" was asserted to meet the "message buffer system" limitation.
    • Motivation to Combine (for §103 grounds): As this ground relied on a single reference, Petitioner argued that TS-23.140 alone rendered the claims obvious by disclosing or suggesting each element.
    • Key Aspects: The core of this argument was that the claimed invention was merely a recitation of the well-established and standardized architecture for MMS. Petitioner detailed how various conditions for message delivery in the MMS standard—such as manual retrieval by a user, a device becoming available on the network, or automatic delivery configurations—constituted the claimed "plurality of message delivery triggers." For example, manual retrieval was argued to be an "asynchronous event with time-critical messaging needs."

Ground 2: Obviousness over Houghton in view of Munson - Claims 1, 5-7, 9-13, and 15 are obvious over the combination of Houghton and Munson

  • Prior Art Relied Upon: Houghton (WO 2006/077283) and Munson (Application # 2009/0240807).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Houghton disclosed a push messaging system where a "push server" (message link server) sends messages over a secure network (using protocols like HTTPS or IP-Sec, forming a "transport services stack") to a "push client" (device link agent) on mobile terminals. While Houghton taught a complete push system with delivery triggers, Petitioner argued that Munson supplied an explicit teaching of a robust store-and-forward "message buffer system." Munson disclosed buffering content in a "series buffer" before pushing it to client devices, including logic for queuing and managing message delivery.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Munson's store-and-forward buffering functionality with Houghton's push messaging system to improve system reliability and flexibility. This combination would prevent message loss when a mobile terminal is offline and provide users with greater control over message delivery, which Petitioner argued was a predictable improvement.
    • Expectation of Success: Petitioner argued for a high expectation of success, as adding buffering (a known technique taught by Munson) to a push messaging system (taught by Houghton) was a well-understood method to enhance performance and would have involved only routine implementation for a POSITA.

Ground 3: Obviousness over TS-23.140 in view of Shen - Claims 2-3 and 12 are obvious over the combination of TS-23.140 and Shen

  • Prior Art Relied Upon: TS-23.140 and Shen (Application # 2005/0207379).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground built upon the TS-23.140 reference to address the specific limitations of dependent claims. For claim 2, which added an "encrypt function," Petitioner argued that while TS-23.140 taught encrypting the communication link (via TLS), Shen explicitly addressed the security vulnerability of store-and-forward systems by teaching an authentication and key-management module to encrypt the messages themselves. For claim 12, which required a "heartbeat message," Shen disclosed periodically sending heartbeat signals to a gateway to determine device reachability.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Shen's teachings with the TS-23.140 MMS system to improve its security and efficiency. Adding message-level encryption as taught by Shen was a direct solution to a known problem in store-and-forward architectures. Similarly, using Shen's heartbeat mechanism was a well-known way to implement the "device becomes available" trigger already present in TS-23.140.
    • Expectation of Success: Success was predictable because Shen explicitly envisioned its security proposal working with MMS-system architecture, and both references described similar messaging environments.

  • Additional Grounds: Petitioner asserted numerous additional obviousness challenges, primarily by adding a single prior art reference to either the TS-23.140 or Houghton-Munson combinations to meet the limitations of specific dependent claims. Key examples included adding Ellison (Patent 7,082,615) for a secure execution environment (claim 4), Rakic (Application # 2009/0282256) for secure authorization signatures (claim 8), Adamczyk (Application # 2008/0162637) for a periodic timer trigger (claim 9), and Gellens (Application # 2005/0144294) for triggers based on data usage (claim 14).

4. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-15 of the ’192 patent as unpatentable.